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When To Complete an I-9 for a Rehired Employee?

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Last Updated on June 3, 2026 / Recordkeeping

U.S. I-9 Form laying on a table with an orange pen laying on top of it.

Question:

We have many employees who return to work for season work or during school breaks..  Do I need to complete a new I-9 for  rehired employees each time they return or just use their old form?

Answer:

According to the US Citizenship and Immigration Service website, if the worker is rehired or continuing in his or her employment and has a reasonable expectation of employment at all times, the employer would not consider his or her return to work a new hire, so the employer does not need to complete a new Form I-9. If the worker does not qualify as continuing in his or her employment, the old form may still satisfy the verification requirements if the worker’s return to work is a rehire within 3 years from the date the employer completed the old Form I-9. The employer can complete Section 3 of the old form or use Supplement B of a new form and attach it to the previous form. If re-verification is not necessary, provide the rehire date and complete the attestation portion of the document.

However, the employer should ensure that they timely complete any necessary re-verification. The employer should complete the rehire date, re-verification and attestation fields if work authorization has since expired. Employers can find additional guidance at the U.S. Citizenship and Immigration Services website – Handbook for Employers: Guidance for Completing Form I-9 (M-274) 

Looking for other I-9 support? Check these out:

Do I Need a New I-9 Form for a Name Change?

Can I Store I-9 Forms Electronically?

Recordkeeping can be a daunting task, especially once you get behind in filing. Keeping some documents accessible, but confidential is extremely important. Clark Schaefer Strategic HR has an easy to use desktop reference to assist with managing employee documentation and record retention. Visit our HR Store page to learn more about this handy tool.